Jennifer Nicole Butler v. Sacramento County Sheriff’s Department, et al.

District Court, E.D. California·Decided March 19, 2026·No. 2:25-cv-01339·Unknown

Opinion

JENNIFER NICOLE BUTLER, Case No. 2:25-cv-01339-TLN-CSK Plaintiff, v. FINDINGS AND RECOMMENDATIONS SACRAMENTO COUNTY SHERIFF’S (ECF No. 8) DEPARTMENT, et al., Defendants.

Plaintiff Jennifer Nicole Butler is representing herself in this action and has filed two amended complaints. (ECF Nos. 7 & 8.) On August 28, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis and dismissed the complaint with leave to amend within 30 days. (ECF No. 4.) The Court subsequently granted Plaintiff an extension to file her amended complaint by December 5, 2025. (ECF No. 6.) As it appears Plaintiff intends to proceed on the First Amended Complaint (“FAC”) filed on March 5, 2026 and dated January 5, 2026 (ECF No. 8, the Court will screen that complaint and disregard the earlier filing at ECF No. 7. For the reasons that follow, the Court recommends that the FAC be dismissed without leave to amend for failure to state a claim. / / / Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a claim on which relief may be granted,” or “seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 (2000) (en banc). A claim is legally frivolous when it lacks an arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). In reviewing a complaint under this standard, the court accepts as true the factual allegations contained in the complaint, unless they are clearly baseless or fanciful, and construes those allegations in the light most favorable to the plaintiff. See id. at 326-27; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). Pleadings by self-represented litigants are liberally construed. Hebbe v. Pliler, 627 F.3d 338, 342 & n.7 (9th Cir. 2010) (liberal construction appropriate even post-Iqbal). However, the court need not accept as true conclusory allegations, unreasonable inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). To state a claim on which relief may be granted, the plaintiff must allege enough facts “to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. A pro se litigant is entitled to notice of the deficiencies in the complaint and an opportunity to amend unless the complaint’s deficiencies could not be cured by amendment. See Lopez, 203 F.3d at 1130-31; Cahill v. Liberty Mut. Ins. Co., 80 F.3d 336, 339 (9th Cir. 1996). / / / Plaintiff brings this Section 1983 action against the following seven (7) defendants: County of Shasta, the Shasta County Sheriff’s Department, Shasta County Sheriff Michael Johnson, Shasta County Deputies Joshua Hamby and Molly Roberts, Shasta County District Attorney Stephanie Bridgett, and Shasta County Deputy District Attorney Dawn Becker.1 Plaintiff alleges that defendants, acting under color of state law, violated her rights under the Fourth, Eighth, and Fourteenth Amendments. (FAC, ¶¶ 1.) The claims stem from an incident on October 8, 2022, when defendants Roberts and Hambly allegedly “entered plaintiff’s property through a secured gate without permission [and] without a search warrant” and began searching “with firearms drawn.” (Id., ¶¶ 21-22.) After telling plaintiff to “drop her weapons,” consisting of a hammer and a block of wood she was using to install flooring, Roberts and Hambly “rushed plaintiff, tackling her to the floor” and injuring her arm, shoulder, hip, and leg. (Id., 23.) Prior to that day, the County of Shasta allegedly failed to equip its vehicles with recording technology and its deputies with body cameras; it also allegedly failed to adequately train staff on warrantless searches and use of force. (Id., ¶¶ 12-16. ) Sheriff Johnson allegedly failed to investigate the October 8, 2022 incident. (Id., ¶¶ 17-18.) Plaintiff asserts that Roberts, Hambly, Johnson, and Shasta County violated her Fourth Amendment rights against unreasonable search and seizure and her Eighth Amendment rights against use of excessive force. (Id., ¶¶ 51-53.) Plaintiff further alleges that in April 2024, Roberts and Hamby coerced a witness to falsely identify her and subjected her to false arrest and false imprisonment, violating her constitutional right to due process. (Id., ¶¶ 26-29.) Plaintiff’s claims against prosecutors Bridgett and Becker stem from their charging plaintiff with resisting arrest and brandishing a weapon in the October 2022 incident; the weapon charge was later dismissed. (Id., ¶¶ 30-33.) However, “plaintiff continues to face 1 All defendants except Becker were named in the original complaint dismissed on August 28, 2025. (ECF No. 4.) prosecution” for one count of resisting arrest in the October 2022 incident. (Id., ¶ 35. ) Plaintiff asserts that Bridgett and Becker violated her constitutional right to access the courts and her right to due process of law. (Id., ¶¶ 49-50.) A. Federal Rule of Civil Procedure 8 Plaintiff’s FAC does not contain a short and plain statement of a claim as required by Federal Rule of Civil Procedure 8. In order to give fair notice of the claims and the grounds on which they rest, a plaintiff must allege with at least some degree of particularity overt acts by specific defendants which support the claims. See Kimes v. Stone, 84 F.3d 1121, 1129 (9th Cir. 1996). A review of Plaintiff’s FAC reveals it consists of “[t]hreadbare recitals of the elements” of her causes of action and fails to state a claim for relief. Iqbal, 556 U.S. at 678. While this problem infects the entire complaint, the Court discusses the FAC’s deficiencies in pleading particular claims below. B. Failure to State a Claim Plaintiff’s FAC fails to state a claim against any defendant under Section 1983. 42 U.S.C. § 1983 “provides a cause of action for the deprivation of any rights, privileges, or immunities secured by the Constitution and laws of the United States.” Wilder v. Virginia Hosp. Ass'n, 496 U.S. 498, 508 (1990) (internal quotation marks omitted). To state a cognizable Section 1983 claim, a plaintiff must allege the violation of a right protected by the Constitution and laws of the United States, and that the alleged deprivation was committed by a person who acted under color of state law. 42 U.S.C. §

Jennifer Nicole Butler v. Sacramento County Sheriff’s Department, et al., (E.D. Cal. 2026).

Jennifer Nicole Butler v. Sacramento County Sheriff’s Department, et al. (Jennifer Nicole Butler v. Sacramento County Sheriff’s Department, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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